PERSONAL DATA PROTECTION POLICY

Ratio 4711 Inc SA is a company with over 20 years of experience in accounting and human resource services. The company respects the privacy of personal information processed during and in connection with the provision of accounting and human resource services, as well as performance of other related activities, and guarantees the utmost protection of such information. This personal data protection and privacy policy is based on the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred to as Regulation (EU) 2016/679).

Information for contact with a Data Protection Officer:

You can contact directly our Data Protection Officer here:

Mr. Anton Rizov, telephone: +35928231384, or write to us at the following address:

120, Pirotska Str., Entr. 2, Office 3, Sofia, Bulgaria, or e-mail anton@ratio4711.com.

This policy aims to inform you about our method for processing of your personal information in our capacity as a Controller and Processor, as well as about your rights. This policy includes the execution of a document – agreement for processing of information related to the personnel, clients, suppliers and managers of the companies. The employer provides their personal details, such as name, National ID No., address, bank details and all other information necessary for the normal functioning of the employment process, including work, salary and human resources for the respective company.

Definitions:

Personal Data

‘Personal data’ means any information with which a natural person can be identified, directly or indirectly, by reference to one or several personal identifiers, such as: name, identification number / National ID No., contact details – location/postal address, telephone number, email address, online identification/IP address, etc. Said identifiers may be part of the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Controller

‘Controller’ means any natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by EU law or the law of the Republic of Bulgaria, the controller or the specific criteria for its nomination may be provided for by EU law or the law of the Republic of Bulgaria;

Processor

‘Processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

Data Subject

‘Data subject’ means a natural person who is identified or can be identified, directly or indirectly, using information which qualifies as personal data.

Personal Data Processing

‘Personal data processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

What types of personal data do we process?

‘Personal data’ means any information about you which can be used to identify you, including information which might be protected in accordance with the applicable national and European legislation.

Personal data which we collect from you and process:

Personal data categories:

1. Clients and users: identification data; information for contact, correspondence and organization of courier/postal deliveries.
2. Employees/workers: identification data, correspondence data, data from a CV, photo and cover letter, marital status, education and qualification, professional experience, personal skills and qualities; work delegations/trips; economic and financial information. Special categories of data which we process for employees/workers: data about health status, about children (in connection with the administration of our employment/service relations with you).
3. Job applicants: data from CV, photo and cover letter, marital status, education and qualification, professional experience, personal skills and qualities.

Source: we receive the data from the data subject and from a publicly accessible source – the Commercial Register with the Registry Agency.

Why are we processing personal data and for what purposes we are going to use data:

In its capacity as a personal data controller, Ratio 4711 Inc SA uses and processes personal data for the purposes of administration of the employment (or service) relations with its employees.

The grounds on which the Ratio 4711 Inc SA accounting company has the right to process your data: the processing of your data is necessary for the performance of a contract with you; the processing is also necessary for compliance with statutory obligations arising for Ratio 4711 Inc SA. Depending on the purpose for which the data are being used, the legal grounds for the processing of your personal data may be one or several of the following:

• Performance of a contract or our intent to conclude a contract: for us to provide the requested services or to undertake steps requested by you before the conclusion of a contract, or in order to provide services requested by you, such as accounting services or personnel and human resource services;
• Legal grounds: if the data processing is required by law (such as when issuing invoices, fulfilling obligations in accordance with the Accountancy Act, the Labour Code, for administration of employment relations, the Social Security Code, the tax legislation, the Tax and Social Security Procedure Code, the Value Added Tax Act, etc.);
• Our legal interests, such as: to ensure the proper functioning of the website, to improve our services (in particular our business interest to be able to better understand your needs and expectations and to improve our services correspondingly);
• Your consent.

Ratio 4711 Inc SA processes personal data with the following purposes:

1. Clients and users: to provide ongoing accounting for your documents and to create annual statements. To prepare offers, contracts, invoices, proforma invoices, acceptance and delivery protocols, storage protocols, as well as any and all other documents necessary in connection with the occurrence, existence, or termination of legal relations with us, including for performance and realization of the rights and obligations thereunder, also in the event of occurred debt; performance of business activities; performance of financial, accounting and accountancy activities and services related to human resources and/or performance of other activities under the Accountancy Act, the National Financial Reporting Standards, the International Financial Reporting Standards, the Social Security Code, the Labour Code, the Taxation of Individual Income Act, the Value Added Tax Act, the Corporate Income Tax Act, as well as other legislation related to the performance of ordinary activities of the clients; the realization and protection of Ratio 4711 Inc SA’s legal interests; in order to compile the monthly salaries of your personnel, as well as all activities related to personnel and human resources – schedules, sick leaves, salaries, insurance, bank details of employees for payment of remunerations, bonuses and all necessary documents for hiring and laying off of employees, etc. Performance of statutory obligations and reporting before state and other competent authorities, institutions, organizations, offices and other regulatory bodies; realization of contact and correspondence with the persons whose data are going to be processed (data subjects) or in order to examine the possibility to provide such services to data subjects.
2. Employees: human resource management; realization and administration of all activities related to establishment, amendment and termination of employment/work/service legal relationships – including for preparation of any related documents (contracts, additional agreements, annexes, documents certifying work tenure, issuance of work certificates, references, certificates, etc.); administration and certifying of employment and work records; in connection with pension, health and social security activities; for assessment of the employee/worker’s capacity for work; for selection of job applicants and personnel; for financial and accounting activities; for bookkeeping in connection with remunerations/fees/other payments or charges to employees/workers under employment, work and civil legal relationships; organizing work delegations, trips and trainings; performance of statutory obligations and reporting before state and other competent authorities, institutions, organizations, offices and other regulatory bodies; administration of indemnities, sick leaves, other leaves, etc.; for establishing of connection via telephone/e-mail, for sending of correspondence related to performance of obligations under official relationships, employment or service contracts; performance of assessment for presence/absence of conflict of interests; for realization and protection of Ratio 4711 Inc SA’s lawful interests;
3. Job applicants: selection of job applicants; performance of assessment for presence/absence of a conflict of interests; for realization and protection of Ratio 4711 Inc SA’s lawful interests;

For how long do we store and process personal data before destroying them?

In order to determine the storage period of your personal data, we apply the following criteria:

• In the event of a subscription for accounting services, we store your personal data for the duration of the contractual relations, unless the law requires a longer storage period, for instance – we collect tax control documents under the Accountancy Act – up to 10 years;
• For documents of people who apply for a position with us – we store the documents for 3 (three) months;

We may store some of your personal details in order to comply with some of our statutory or regulatory obligations, as well as to be able to exercise our rights (e.g. to file claims at the court) or for tax and accounting purposes.

After the expiry of the stated periods, the personal data are anonymized or deleted in the Company’s electronic systems. Hardcopy files containing personal data are also destroyed.

With whom can we share personal details?

Ratio 4711 Inc SA shall observe and protect the confidentiality of personal data. If the requirements of the law are met, the Company may disclose personal data to state and municipal authorities (National Revenue Agency, National Social Security Institute, Ministry of Interior, judicial authorities, regulatory authorities, local governing authorities, etc.);

In compliance with its statutory requirements, the Company may be obligated to disclose personal data of subjects or persons under service provision relationships if this is expressly requested by state or municipal authorities. When disclosing personal data to state authorities, we will aim to cooperate with such authorities if they have any queries, but we will also aim to respect the rights and personal privacy of the subjects, to the extent that it is possible and lawful.

• Banks for the purposes of remuneration payments and others;
• Courier companies and postal operators – for correspondence with natural persons who are data subjects.

Your personal data may also be processed on our behalf by our suppliers. For example, we may delegate services which require processing of your personal data to providers of IT services, hosting services, maintenance of our data bases, software and applications which may contain data bout you (such services sometimes entail access to your personal data for the performance of specific tasks), social networks, web analytics and search engines, use of tools for adjustment of user-generated content, postal services and deliveries, advertising, marketing, digital and social media agencies who will assist us in the organization of advertising and marketing campaigns, for analysis of their efficiency and management of your contacts and questions, as well as subcontractors under agreements.

The disclosure of data shall only be carried out if there are valid reasons to do so and with a written agreement and undertaking assumed by the recipients of the data to ensure an adequate level of data protection.

How do we protect personal data?

Ratio 4711 Inc SA is committed to protect your personal data. We implement appropriate technical and organizational measures to guarantee observance of the personal data protection laws.

We have adopted the necessary internal policies and implemented measures for protection of personal data. Our employees are well-acquainted with the personal data protection requirements. We have introduced multiple measures for effective application of the data protection principles, including, but not limited to:

• Guaranteeing continual confidentiality, integrity, availability and stability of the processing systems and services;
• Measures in the event of a physical or technical incident for timely recovery of the availability of and access to the personal data;
• An internal process for regular testing, assessment and evaluation of the effectiveness of the technical and organizational measures in order to guarantee secure processing;
• Measures which allow immediate assessment whether there is a personal data security breach and notification of the Commission for the Protection of Personal Data and the affected parties;
• Technical and organizational measures for prevention of accidental or unlawful destruction, loss, change, unauthorized disclosure or access to personal data.

Your rights in connection with your personal data

In accordance with the Bulgarian legislation, you have the following rights in connection with your personal data which are being processed by Ratio 4711 Inc SA:

1. Right to receive access to your personal data which are being processed by the company, and to receive a copy of them;
2. In the event of gaps or inaccuracy in the data processed by the Company, your personal data shall be corrected after provision of the proof necessary to establish the need for correction;
3. The right to request deletion of your data if the necessary conditions are present. Such instances may be: the goal for which the data have been collected has been achieved; you have withdrawn your consent, if the processing is based on consent and there a no other legal grounds for it; your data are being processed unlawfully, etc.;
4. In the scenarios set forth by the law, you have the right to request the processing of your personal data to be limited;
5. In the scenarios set forth by the law, you have the right to object against the processing of your personal data;
6. You can exercise your right of data portability and request that your data are provided in a structured, widely usable and machine-readable format;
7. You can withdraw your consent if the processing of your data is based on your consent.

How to contact us?

If you have questions or complaints about our personal data protection and confidentiality policy or the ways and goals for which we are using your personal data, you can contact us at the following address:

120, Pirotska Str., Entr. 2, Fl. 1, Apt. 3, Sofia, Bulgaria or email: anton@ratio4711.com

Our personal data protection officer is Anton Rizov, email: anton@ratio4711.com.

Updating of the personal data protection and confidentiality policy

This policy may be updated periodically to reflect changes in the practices for protection of the personal data of employees and/or clients of Ratio 4711 Inc SA.

This policy is confirmed by the order of the General manager Anton Rizov on 25.05.2018.

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